The federal government sets forth the basic grantee financial management standards in 2 CFR Part 220, which apply to all grant programs and provides for the following:
- accurate, current, and complete disclosure of the financial results of each grant program;
- accounting records which identify the source and use of grant funds;
- account control for all grant funds, property, and other assets.
At UWF, these requirements are met through a uniform accounting system that provides the basic controls as well as accounting reports that will assist faculty and their staff in managing contracts and grants. The university accounting system is under the jurisdiction of Financial Services and the vice president\chief financial officer for Business, Finance, & Facilities. Questions or inquiries concerning accounting should be addressed to RSP at 850.474.2824.
Audits & Access to Records
Internal and external constituencies (auditors, program or grants officers, sponsor's designees for administration and oversight, etc.) often conduct reviews of different levels of effort to assess or monitor program effectiveness. These reviews may be informal site visits of a technical or program officer or may be a full request for a self-study prior to a site visit or a formal audit. In any circumstances of a review of the administration and management of sponsored research projects, programs, or related activities, RSP is charged to coordinate and assist the PI or department or institute/center in preparing for and responding to such review requests. In cases of external reviewers, UWF IAMC must also be apprised of the review and will determine if staff from this department should be involved. All responses for such external reviews should be approved by RSP and the IAMC offices before being communicated to the external entity.
Compliance with guidelines, rules, and procedures in one project often affect the status of the institution at large. Therefore, such reviews are extremely important in demonstrating the university's overall eligibility for funding and participation in such programs. A coordinated response to any such request is critical. PIs and other designated staff have the responsibility to work with the two offices to provide appropriate response and information as needed.
This section provides the Principal Investigator (PI), departmental support personnel, and administrative officers with guidelines for external review and internal or external monitoring in regard to sponsored research (or related) projects. As the office charged with oversight of grant projects and Uniform Guidance compliance, RSP is the internal authority on program or budget compliance. Therefore, coordination with RSP staff is critical for any visits or inquiries regarding projects.
All records are subject to audit and any authorized representative of the grantor (prime agency or first-tier recipient), the state or the university shall have right of access to any books, documents, papers or other records of the grantee which are pertinent to the contract or grant. The right of access shall not be limited to the required retention period but shall last as long as the records are retained.
UWF falls under Uniform Guidance 2 CFR regarding federal audit requirements on grants, contracts, and other agreements. RSP should be promptly informed when a sponsor announces its intent to conduct a contract or grant audit. Staff from the appropriate fiscal office will accompany the auditor and be available during the visit to help interpret and understand the requests of the audit. Audit visits should be prepared for as soon as notification is received in order to assure maximum coordination of staff time and availability of records.
The following is a non-exclusive list of the types of reviews, audits, and monitoring which internal/external authorized personnel may request of a PI, budget manager or administrative unit:
- Audits - UWF Internal Auditing and Management Consulting Department (IAMC), Florida Auditor General, Office of Management and Budgets (Uniform Guidance), or any sponsor agency or authorized representative on any aspect of project;
- Pre-contract or contract negotiations and discussions;
- Reviews (program, participant, sponsor or compliance);
- Monitoring visits (program, progress, sponsor);
- Site visits (program, progress, sponsor);
- Progress or interim visits/reviews; and
- Organized inquiries regarding the functions or activities related to a project, program, or institute/center, which is sponsored by or related to a sponsored project.
Audits, reviews and monitoring may take a number of different forms including but not limited to the following:
- Formal procedures with entrance and exit conferences.
- Desktop reviews (usually consisting of web site access and reviews)
- Paper only (requests for interim reports, financial records or supporting documentation on financial reports submitted)
- Verbal (phone, fax, or e-mail requests for data)
- In person (actual schedule of meetings with or visits by internal or external persons to review some aspect of project performance or management).
In all cases, the notified party has certain responsibilities to coordinate and cooperate with the relevant campus offices involved in the review. Some useful information on audits, investigations, and reviews is available from the UWF IAMC internal web site.
The PI is primarily responsible for the technical conduct and management of the project to assure that contractual and regulatory conditions are met and to make certain that the program stays within its budget. Costs associated with a project are expected to be charged directly to the project. The PI, department chair, and college dean are all expected to exercise responsible judgment in the administration of the project, particularly with regard to the terms of the agreement and university policies and procedures. Financial liabilities which result from failure to comply with the grant or contract become the responsibility of the PI, department, and college.
The PI is responsible for project implementation, assembling the necessary staff, properly expending the funds, and conducting the project as described in the proposal and agreed to by means of the award notification.
The PI must direct the work so that it will be completed within the performance period and with the funds authorized; otherwise, a request for supplemental funds or a no-cost time extension must be initiated. Researchers are expected to familiarize themselves thoroughly with the regulations applicable to their specific project/agency.
The PI may authorize changes when they are in compliance with the agency's cost principles, as well as the state of Florida's fiscal regulations, and if the goods or services are directly related to the sponsored project. Salaries and wages may be authorized by the investigator only if they are in accordance with Uniform Guidance 2 CFR 200.
The PI has first-line responsibility for managing expenditures within the fiscal regulations and amounts specified by the sponsor. The PI must carefully analyze the Information Navigator report Grant Inception-To-Date w/ FUND (RSP000008) report to see that all items presented are correct and that appropriate funds (cash and budget authority) are available. The PI also has the responsibility of initiating or coordinating appropriate adjustments as each situation dictates. It is suggested that this analysis take place no less than monthly in order to provide for timely action if needed.
The PI is responsible for any exempt purchases (see Expenditure Restrictions & Guidelines) purchased in conjunction with a grant and must provide written documentation stating the purpose, list of attendees, and authorized approval.
The PI is responsible for ensuring that the cost sharing commitment is met on a grant or contract and to provide RSP the documentation necessary to track cost sharing commitments.
The PI must approve all expenditures such as, but not limited to, personnel actions, purchases, travel, transfers or recharges of expenditures, ACRES, and distribution of funds to other university accounts.
The PI/project director must accomplish the following:
- Notify RSP and/or IAMC staff of any contact from external personnel requesting review or monitoring of a sponsored research project or an institute/center.
- Cooperate with RSP coordinator in reviewing and preparing for the upcoming review.
- Forward all pre- and post-visit correspondence to appropriate parties.
- Adjust future project management and oversight to address any findings or determinations.
RSP must accomplish the following:
- Assist PI/Director in preparing required materials and documents for upcoming review.
- Coordinate financial and related reports needed or assist in retrieval of additional supplemental documentation.
- Participate in all meetings related to review (before, during, and after).
- Assist PI/Director in preparing response to any comments, findings, or determination.
- Follow up to address any deficiencies in university policy and or procedures as part of on-going quality assurance and compliance issues on future activities.
- Participate in and/or coordinate all contract negotiations or discussions of terms and conditions with external sponsors.